Description of The Logic and Practice of Transfer Pricing, 2nd Edition by Sam Sim:
This second edition, recommended for the UK Chartered Institute of Taxation Advanced Diploma in Taxation, is authored by two practitioners with extensive experience working in and leading global in-house teams for US and European multinational enterprises. Drawing on decades of combined experience in transfer pricing and taxation, the authors present the subject in a clear, structured, and accessible manner, supported by diagrams and practical examples. The book explains the core principles of transfer pricing, key considerations in conducting functional analysis (including sample functional templates) and benchmarking, transfer pricing within global value chains, documentation requirements, risk management, and the handling of transfer pricing disputes.
Includes:
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Developments arising from the G20/OECD BEPS 2.0 project
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Updates reflecting the OECD Transfer Pricing Guidelines 2022
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New OECD guidance on Chapter X relating to financial transactions
Table of Content of The Logic and Practice of Transfer Pricing, 2nd Edition by Sam Sim:
Part I - The Core
Chapter 1: The Intuition Behind Tax Transfer Pricing
Chapter 2: The OECD Approach
Chapter 3: The Arm’s Length Principle
Chapter 4: Applying the Arm’s Length Principle: Comparability
Analysis
Chapter 5: Pulling It Together
Chapter 6: Documentation
Part II - Key Areas of Transfer Pricing and Base Erosion and
Profit Shifting (‘BEPS’)
Chapter 7: Intra-Group Service Charges
Chapter 8: The G20-OECD Initiative Against Base Erosion and
Profit Shifting
Chapter 9: Special Considerations for Intangibles
Chapter 10: Business Restructuring
Chapter 11: Permanent Establishment and the Authorised
OECD Approach
Part III - Transfer Pricing in Motion: Practical Perspectives
from Implementing Transfer Pricing
Chapter 12: Audit and Dispute Resolution
Chapter 13: Transfer Pricing in Practical Context
Chapter 14: Developing the In-house Transfer Pricing Capability
Chapter 15: Practicing Transfer Pricing in Non-OECD Developing
Countries
Part IV - Cutting Edge Developments
Chapter 16: Financial Transactions
Chapter 17: Making Sense of Base Erosion and Profit Shifting
(BEPS) 2.0
About the Authors:
Sam Sim has served on the UK Chartered Institute of Taxation Advanced Diploma in International Taxation Committee and was Regional Vice-President (Europe, Middle East, Africa, Asia, and Latin America) of the Tax Executives Institute. He also chaired the Capital Markets Tax Committee’s Transfer Pricing sub-committee. Mr. Sim has led global teams as Deputy Global Head of Transfer Pricing at a major European multinational and as Transfer Pricing Geo Leader for EMEA and Asia Pacific at a leading US technology multinational, with additional board-level experience in audit, risk, and disciplinary committees. He is a former tax attorney in New York, a Chartered Accountant in Singapore, and holds graduate degrees in Law, Economics, and Accounting. He has also co-authored the notable book Asian Voices: BEPS and Beyond (IBFD), a leading reference on BEPS in Asia.
Ziad Rahman is a Transfer Pricing expert with over twenty years of experience in the Asia Pacific region. He has developed his expertise through roles in the economist practice of a tax authority, in-house tax teams, a Big Four accounting firm, and by running his own boutique Transfer Pricing consultancy. Ziad has also delivered numerous Transfer Pricing seminars and training programs, including presentations as part of the OECD outreach initiatives.
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